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Not following your own programs results in OSHA citations - OSHRC vacates (1910.176)
On October 3, 2016, a warehouse employee was seriously injured when seven crates containing 94-pound struts fell from a stack onto him as he was inventorying them. There were no witnesses to the accident, and the injured employee has no memory of the event. Following an inspection by OSHA, the Secretary concluded the cause of the incident was the instability of the stack of crates. The Secretary issued...
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Does your Emergency Response Plan use DOE's "Protective Action Criteria" (PAC)
The Department of Energy has a little-known database that is a goldmine for emergency planners and responders.  This database is called the Protective Action Criteria for Chemicals (PACs), and it uses a hierarchy-based system of the three (3) exposure guideline systems:  Acute Exposure Guideline Levels (AEGLs) Emergency Response Planning Guidelines (ERPGs), and Temporary Emergency Exposure...
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WorkSafeBC Ammonia Inspection initiative Update (June 2018)
From the WorkSafeBC annual report… In 2017, following work-related deaths at an ice rink, we utilized the Risk Analysis Unit’s research on ammonia exposure to launch a three-phased province-wide inspection initiative focusing on ammonia exposure to ensure that owners and employers of facilities using ammonia are correctly managing the risks associated with the toxic gas. In late 2017, the...
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1899 G6
OSHA and "No. 54 drill-size openings" (Anhydrous Ammonia)
Have you ever wondered what a “No. 54 drill-size Opening” is?  This is a phrase used in OSHA’s 1910.111, Storage and handling of anhydrous ammonia.  In simple terms, OSHA has established that if the potential leak is through an opening of No. 54 drill-size or smaller then, the opening need not be protected by an excess-flow valve.  Here’s what I am talking...
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Should a PRD header/manifold system have "intervening valves"?
This is a topic that is near and dear to me, as it is one I learned very early on in my career as a means to safely perform PRD work on an RV or RD that is connected to a header/manifold.  Although this design MUST be adequately done AND must be managed very tightly, it can add a level of safety for workers doing work associated with the relief system or header/manifold. Let’s first squash...
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Frozen Tank Vents Probed in Missouri Bulk Plant Flammable Liquid Storage Tank Explosion and Fire
Regulators in Missouri are cautioning aboveground storage tank (AST) owners and managers everywhere to beware of icy weather conditions that could affect the safe operation of vents. Investigators are examining whether two frozen vents could have led to a bulk-plant fire in Marshall, Mo. about 80 miles (129 kilometers) east of Kansas City as a driver was unloading fuel from his truck into a standing...
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OSHA PRCS Citation @ Chemical Manufacturer (Oxygen Deficiency & $64K)
OSHA has cited a Chemical Manufacturer after an employee died due to lack of oxygen while cleaning the inside of a railcar. A second employee who tried to rescue the co-worker was also overcome but survived. OSHA has proposed $64,857 in penalties. The facility was cited for failing to provide respiratory protection; properly ventilate a confined space; implement a permit-required limited space...
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2k9zzKs
2018 Photo of the Week #23 (Smoking Area)
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2018 Video of the Week #23 (Car ignites LNG spill on roadway)
This is a great example of “know your surroundings”!  LNG is INVISIBLE, even on the most humid of days, when its at its LEL – meaning, although there is no “cloud” there is a good chance you may be in a flammable atmosphere if your around an accident.  These people had no way of knowing the trailer was leaking, but this video shows us how a flammable gas/vapor...
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EPA EPCRA and CAA GDC citations @ egg production facility (NH3, with 2K pound release & $70K)
Respondent is the owner or operator of an egg production facility which employs a refrigeration process using anhydrous ammonia in its egg production system. Pursuant to Section 112(r)(1) of the CAA, also known as the General Duty Clause, the owners and operators of stationary sources producing, processing, handling or storing substances listed pursuant to Section 112(r)(3), or any other extremely...
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EPA CAA GDC citations @ chemical manufacturing facility (Flammables and Reactives & $3K)
This case is being posted, even though the citation was under $10,000 because it is a GDC case and involved improper storage of materials that would react to create an extremely hazardous substance.  EPA used both NFPA 30, 2015 and the IFC, 2015; as well as NFPA 704 in their assessment.  The respondent has owned and operated the chemical manufacturing facility since 2001.  Respondent...
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Details matter in our SOPs/SWPs
This is a classic.  Details matter, contrary to what many want to claim about safety plans, programs, practices, and operating and maintenance procedures. The fact is, there MUST be a balance between details and length and complexity.  Some jobs will need a 10-page procedure, and some will need a half-page.  The idea that shorter is always better is a falsehood driven by laziness and...
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